Passenger air transport

Qualifying · 0% eligible

Forensic Analysis

DZ requiredSubstance: HIGHAI-derived

Passenger air transport is treated as a Qualifying Activity when conducted internationally. Forensic scrutiny focuses on the location of 'Core Income Generating Activities' (CIGA), specifically flight operations, crew management, and safety oversight. Income from ancillary services (e.g., duty-free, excess baggage) must be strictly partitioned to ensure they do not exceed the de minimis threshold if not explicitly listed as qualifying.

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Legal Reference

Ministerial Decision No. 229 of 2025, Article 2, Clause 1(f)

Audit Red Flag

Misclassification of domestic point-to-point transport as international transport to exploit the 0% rate

3 licensable activities under this classification

Air Lines Of Passengers & Cargo TransportationExternal approval required

Helicopter Rental & OperationExternal approval required

Passenger Transport services by Taxi AircraftExternal approval required

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